International

  • December 03, 2021

    Canadian Justices Toss Taxes On Company's Foreign Affiliate

    A Canadian holding company doesn't have to pay taxes on a Barbados bank it owned, managed and capitalized because those activities cannot be considered business activities that would make it subject to taxation, the Supreme Court of Canada ruled Friday.

  • December 03, 2021

    CPA Tied To Russian Gas Co. Faces More Tax Charges

    A Florida accountant has been hit with additional federal tax evasion charges in a criminal case accusing him of hiding $93 million overseas that he earned through ties to a Russian gas company.

  • December 03, 2021

    Liberal Democrats Want To Nix Surcharge For UK Small Biz

    The British opposition Liberal Democrats called for scrapping a new 1.25% surcharge on employee and employer social security taxes, saying small businesses shouldn't have to pay any social security tax for their workers for two years.

  • December 03, 2021

    Taxation With Representation: Skadden, Latham

    In this week's Taxation With Representation, insurance broker Arthur J. Gallagher & Co. will acquire the reinsurance broking arm of rival Willis Towers Watson, industrial 3D printing business Essentium will go public with blank-check company Atlantic Coastal, and Distributed energy firm Voltus will go public by merging with special purpose acquisition vehicle Broadscale Acquisition Corp.

  • December 03, 2021

    Italian Accused Of Extorting Vatican Faces UK Extradition

    A key suspect in a Vatican corruption scandal has been ordered by a London court to be extradited to Italy, where he faces money laundering charges arising from allegations that he extorted €15 million ($16.8 million) from the Holy See.

  • December 02, 2021

    IRS' Math Correct In Vineyard Owner's FBAR Row, Court Told

    A California federal court should affirm the Internal Revenue Service's calculation of roughly $440,000 in foreign bank account reporting penalties against a vineyard owner, the U.S. government said, arguing the computation was based on the law and agency procedures.

  • December 02, 2021

    $824K FBAR Judgment Satisfied, US Tells Court

    A New Hampshire woman who failed to report foreign bank and financial accounts satisfied an $824,000 judgment against her, the U.S. government told a federal court.  

  • December 02, 2021

    Netflix To Pay Australia Tax On Subscriber Revenue, Co. Says

    Netflix Australia will pay Australian taxes on subscription revenue from customers there through a local limited risk distributor next year, after having previously used a Netherlands-based company to book the income, a spokesperson told Law360 on Thursday.

  • December 02, 2021

    EU VAT Gap Fell by €13.1B In 2019, Report Says

    The difference between the value-added tax expected and collected in the European Union dropped to €134 billion ($152 billion) in 2019 — the latest year for which statistics are available — from €147.1 billion the previous year, a report said Thursday.

  • December 02, 2021

    Hungary, Estonia Holding Up EU Minimum Tax, Adviser Says

    Hungary and Estonia are obstructing the European Parliament's efforts to expand a group that assesses corporate tax plans in a move to delay EU enactment of a globally agreed 15% minimum tax, a Greens parliamentary adviser told Law360 on Thursday.

  • December 02, 2021

    Nigeria Declined OECD Tax Deal Over Fears Of Lost Revenue

    Nigeria didn't sign the global tax agreement that most of the world's economies agreed to because its officials feared a net negative impact on revenue, according to a statement provided to Law360 by the country's tax authority.

  • December 02, 2021

    OECD Tax Chief Defends 15% Minimum Tax Rate

    Pascal Saint-Amans, the OECD's top tax official, defended the 15% minimum effective tax rate recently agreed to as part of a historic global deal on Thursday, saying that level is "high" compared with Ireland's 12.5%.

  • December 01, 2021

    No Tax Court Redo For Coke In $3.3B Transfer Pricing Row

    Coca-Cola can't challenge its loss in a $3.3 billion transfer pricing dispute with the IRS after the U.S. Tax Court found the company filed its reconsideration bid far past the typical deadline, counsel for the company confirmed Wednesday.

  • December 01, 2021

    House Subcommittee To Discuss Hidden Wealth

    The House Ways and Means Oversight Subcommittee will hold a meeting on the subject of hidden wealth next week, the subcommittee chairman said Wednesday.

  • December 01, 2021

    US Asks Court To Sell Properties To Cover $1.1M FBAR Fine

    A New York federal court should sell a man's properties to cover more than $1.1 million in penalties for failing to report foreign bank accounts that it found him liable for more than a year ago, the U.S. government said Wednesday.

  • December 01, 2021

    Tax Pros Say Int'l, Fed. And State Tax Connections Intensifying

    Tax professionals should be on the lookout for several key developments that are arising out of strengthened connections between federal, international and state and local tax as tax regimes are overhauled, conference panelists said Wednesday.

  • December 01, 2021

    Saint-Amans Says Model Rules For Minimum Tax On The Way

    Delegates at the Organization for Economic Cooperation and Development have agreed on model rules to help countries enact their recent 15% global minimum tax deal, OECD tax chief Pascal Saint-Amans said Wednesday, declining to specify a release date.

  • December 01, 2021

    OMB To Review Foreign Tax Credit Rules

    Final rules regarding the foreign tax credit and foreign-derived intangible income regime under the 2017 tax overhaul are pending review with the Office of Management and Budget, the office said.

  • December 01, 2021

    HMRC Eyes Tweaks To Corp. Tax System Following Review

    HM Revenue & Customs said it plans to update the U.K.'s tax compliance system for large corporations in response to a consultation in which businesses reported they wanted more clarity on international tax rules and cooperative compliance.

  • December 01, 2021

    Business Lobby Warns EU Not To Go Beyond OECD Tax Deal

    European Union business lobby urged the bloc's executive arm to stick closely to the international tax deal facilitated by the Organization for Economic Cooperation and Development and agreed on by nearly 140 jurisdictions or risk undermining the entire project.

  • December 01, 2021

    Taiwan Lawmakers OK Hike Of Top Tax Dodge Fine To $3.6M

    Taiwan's legislature passed an amended tax code that would raise the maximum fine for criminal tax evasion to 100 million New Taiwan dollars ($3.6 million) for large, profitable businesses, according to a Ministry of Finance news release.

  • December 01, 2021

    Akerman Lands Ex-Greenberg Traurig Partner For Tax Practice

    Akerman LLP is adding a former Greenberg Traurig LLP partner with longtime experience serving a range of clients in federal, state, local and international tax matters to its New York office, the firm said.

  • December 01, 2021

    South Korea Delays 20% Capital Gains Tax On Crypto

    South Korea's legislature voted to delay imposing a 20% capital gains tax on cryptocurrency assets until January 2023, according to a government news release.

  • November 30, 2021

    Africa Wants Tax Revenue To Replace DSTs, Panelists Say

    African tax officials and experts said Tuesday that the continent is unlikely to drop digital services taxes without assurances the revenue will be replaced under a proposed global tax overhaul.

  • November 30, 2021

    EU Scraps Digital Tax, Leaving Gap In Bloc's Budget

    The European Union's proposed digital levy, intended to help settle the bloc's unprecedented €750 billion ($850 billion) borrowing on behalf of its 27 members during the pandemic, has been suspended indefinitely, a senior European official confirmed to Law360 on Tuesday.

Featured Stories

  • 7 Things Tax Pros Are Grateful For This Thanksgiving Season

    Amy Lee Rosen

    From the continued extension of federal and state tax deadlines because of the pandemic to clarification on forgiven Paycheck Protection Program loans and the agreement on a global corporate tax overhaul, tax attorneys are grateful for many things this Thanksgiving. Here, Law360 reviews seven developments tax professionals are thankful for this year.

  • Corp. AMT Plan May Blur Line Between Tax, Financial Data

    Natalie Olivo

    A proposed alternative minimum tax based on financial statements has sparked concerns among accounting experts, who worry that blending two separate systems for measuring corporate income could undermine the underlying — and intentionally different — purposes of each one.

  • FATCA Data Transfers Likely Safe From Court Challenges

    Natalie Olivo

    A European Union court ruling that invalidated mechanisms used to transfer personal data across the Atlantic is unlikely to bolster privacy-related challenges against the U.S. Foreign Account Tax Compliance Act's information exchange agreements, which have so far survived litigation overseas.

Expert Analysis

  • What The New OECD Double-Tax Procedure Statistics Tell Us

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    Monique van Herksen and Clive Jie-A-Joen at Simmons & Simmons consider the Organization for Economic Cooperation and Development’s recent report on double taxation cases resolved in 2020 under the mutual agreement procedure process, and examine whether the process has improved dispute resolution mechanisms since its implementation five years ago.

  • Navigating FCPA Risks Of Minority-Owned Joint Ventures

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    The U.S. Department of Justice and U.S. Securities and Exchange Commission will likely continue to focus on third-party risks under the Foreign Corrupt Practices Act, so companies with minority-owned joint ventures should take several steps to mitigate related compliance challenges, say Ben Kimberley at The Clorox Company and Addison Thompson at Covington.

  • Questions To Ask If Doing Business In A Corruption Hot Spot

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    Businesses facing new scrutiny after the U.S. Department of Justice's recently announced task force for combating human trafficking in Central America, the release of the Pandora Papers and continuing fallout from 2019's Panama Papers, should address compliance risks by having employees ask three questions about every transaction, say attorneys at White & Case.

  • How The Global Tax Agreement Could Backfire For Biden

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    If the $3.5 trillion spending package fails, the federal tax code will not conform to the recent 15% global minimum tax agreement spearheaded by the U.S., which would embarrass the Biden administration and could lead to retaliatory tax measures by other nations, says Alex Parker at Capitol Counsel.

  • Pandora Papers Reveal Need For Greater Tax Enforcement

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    The recent Pandora Papers leak is a reminder of the importance of transparency laws and proper funding for enforcement efforts against tax evasion as bad actors increasingly operate in the shadows, says Daren Firestone and Kevin Crenny at Levy Firestone.

  • Parsing New Int'l Tax Reporting Rules For Pass-Throughs

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    Attorneys at Grant Thornton unpack the Internal Revenue Service’s new pass-through entity reporting requirements for international tax matters and the accompanying guidance for penalty relief, and suggest how companies should prepare for what may be the most significant change to the partnership compliance function in decades.

  • A Look At Global Tax Enforcement Developments: Part 2

    Excerpt from Practical Guidance
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    Sean Craig at LexisNexis examines recent investigations by the Joint Chiefs of Global Tax Enforcement and their impact on U.S. taxpayers, as well as the growing significance of transfer pricing disputes and policies for future enforcement.

  • A Look At Global Tax Enforcement Developments: Part 1

    Excerpt from Practical Guidance
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    Sean Craig at LexisNexis looks at how international initiatives, such as the Joint Chiefs of Global Tax Enforcement, are addressing cryptocurrency-related tax evasion, and how the COVID-19 pandemic and increasing demands for governmental welfare programs are driving global tax policy.

  • EU Climate Plan Should Involve Taxing Pollution, Not Borders

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    In order to crack down on greenhouse gas emissions, the European Union proposes to levy carbon emissions at its borders and to overhaul its long-standing energy tax framework, but the latter would hold polluters directly accountable, giving it the better chance for success, says Rebecca Christie at Bruegel.

  • Prepare For Global Tax Regime's New Biz Dispute Risks

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    Companies should take steps to mitigate the business dispute risks of the new international tax framework, which over a hundred countries agreed to in July, as implementing the new regime will be expensive and require substantial organizational restructuring efforts, says Tim McCarthy at Dykema.

  • Prepare For More Audits Of Tax Info And Withholding Filings

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    Financial institutions and other corporate taxpayers should focus compliance efforts on tax information reporting and withholding, given recent indications from the Biden administration that the IRS will increase enforcement, and the administration's need to fund its infrastructure plan and other costly initiatives, say attorneys at Mayer Brown.

  • Anti-Boycott Compliance Still Key In UAE Business Dealings

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    Notwithstanding recent amendments to U.S. anti-boycott laws that reflect the United Arab Emirates' withdrawal from the Arab boycott of Israel, companies doing business in the UAE and elsewhere still need to maintain effective anti-boycott compliance programs to avoid reporting violations or penalties, says Howard Weissman at Miller Canfield.

  • 9th Circ. Adds Pressure To Reject Substance Over Form

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    The Ninth Circuit’s recent decision rejecting taxes on a family's Roth IRA payments that were made through a foreign sales corporation represents a refreshing trend among federal appeals courts to reject substance-over-form principles and instead look to congressional intent, say Lawrence Hill and Caitlin Tharp at Steptoe & Johnson.